On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more
3/13/2025
/ Appeals ,
Chevron Deference ,
Corporate Taxes ,
FedEx ,
Foreign Tax Credits ,
Government Agencies ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Offsets ,
Regulatory Requirements ,
SCOTUS ,
Statutory Authority ,
Tax Avoidance ,
Tax Credits ,
Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025.
TAX-CONTROVERSY-RELATED DEVELOPMENTS -
The previous IRS...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025....more
On January 22, 2025, the US Department of Justice (DOJ) announced the indictment of seven individuals in the largest Employee Retention Credit (ERC) fraud scheme to date. According to the indictment, the defendants filed more...more
1/29/2025
/ Coronavirus/COVID-19 ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Employee Retention ,
Employer Liability Issues ,
Enforcement Actions ,
Fraud ,
Indictments ,
IRS ,
Paid Family Leave Law ,
Paid Leave ,
Sick Leave ,
Tax Credits ,
Tax Refunds ,
Tax Returns
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6, 2025 – January 10, 2025....more
1/23/2025
/ Digital Assets ,
Income Taxes ,
IRS ,
Proposed Rules ,
Regulatory Agenda ,
Reporting Requirements ,
Retirement Plan ,
Tax Credits ,
Tax Planning ,
Tax Reform ,
Tax Refunds ,
Tax Returns
We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several times before, but this...more
FedEx Corporation, previously the victor in a closely watched dispute regarding the government’s regulatory attempt to prevent taxpayers from claiming foreign tax credits on offset earnings (131 AFTR 2d 2023-1284 (W.D. Tenn....more
In United States v. Grigsby, Docket No. 22-30764, the US Court of Appeals for the Fifth Circuit held that a refund claim based on claimed Internal Revenue Code (IRC) Section 41 credits was erroneous. Cajun Industries LLC, a...more
In this article, we discuss some basic considerations for preparing a protective refund claim. These considerations are particularly relevant for taxpayers whose statutes of limitations for refund claims are expiring soon and...more